Compliance and Ethics Program Best Practices Resource Guide
Policies
Standards, procedures and written controls help to prevent and detect unethical conduct.
Key Resources:
Create one central, cross-functional repository for policies, procedures, guidelines, etc., Communicate new and revised policies to applicable parties (employees, independent contractors, vendors, etc.), Implement and distribute a policy development process, Share the BBNC Code of Ethics and Business Conduct
Compliance Structure
A Compliance Structure creates various levels of oversight by knowledgeable individuals to ensure that applicable policies and written standards of control are followed.
Key Resources:
Define the scope of your industry-specific, risk-based compliance program, Document your compliance program strategic plan and obtain leadership approval, Identify dedicated compliance personnel or personnel who accomplish compliance program functions, Create a compliance budget
Education, Training & Communication:
Education on relevant laws, regulations, and policies so that expected conduct in the workplace reduces the probability of unethical conduct.
Key Resources:
Training: Offer training in multiple formats (electronic, live, interactive), Track training completion, Measure employee satisfaction with training, Document the effectiveness of training (i.e., is there a reduction in risk because people are trained?
Education (Content): Complete Annual Compliance Training, Identify and complete industry-specific training (mandated by industry, regulations or legislation), Identify and complete training that supports employee development and aligns with strategic goals, Provide training on new and revised policies, as requested or needed.
Communication: Communicate compliance events (policies, training, initiatives, industry changes), Offer communication in multiple formats (email, website, intranet, newsletter)
Culture of Integrity
Duty to ensure that senior leadership models and rewards high ethical behavior by delegating authority, hiring, and promoting others with a proven record of high character.
Key Resources:
Promote a Speak Up, Speak Out culture, Reinforce the importance of compliance and ethics and obtain leadership support, Define specific compliance and ethics expectations, Assess employee perception of culture using culture surveys, Work with key stakeholders to remediate cultural issues
Monitoring, Auditing & Reporting:
Continuous and routine review of business activity allows issues to be identified early on and remedied quickly. Open lines of communication increase early detection of issues and help identify areas or topics that require additional monitoring or education.
Key Resources:
Monitoring: Conduct wellness checks (via telephone, video call, or live) to promote a culture of integrity and appreciate employees who demonstrate ethical behavior, Maintain a database of applicable laws and regulations and track changes, as needed, If red flags appear, report the issue using the established reporting mechanism.
Auditing: Collaborate with the Internal Audit function to ensure that the compliance program meets industry standards
Reporting: Maintain an anonymous hotline for employees to report misconduct, Create multiple channels for employees to report misconduct, Communicate the importance of speaking up and protections (i.e., no retaliation, anonymous reporting) for employees who report misconduct, Solicit employee feedback regarding reporting mechanisms.
Incentives & Discipline
Expectations are met through effective checks and balances and taking consistent and appropriate disciplinary measures to discourage unethical conduct while also rewarding those who demonstrate ethical behavior.
Key Resources:
Empower supervisors to consider compliance behavior in performance reviews, Incentivize ethical behavior with recognition, awards, and prizes (i.e., via Spotlight on Compliance Week), Create and distribute discipline policy/guidelines, Create a disciplinary database to ensure consistent behavior.
Internal Investigations
Expectations are met through effective checks and balances and taking consistent and appropriate disciplinary measures to discourage unethical conduct while also rewarding those who demonstrate ethical behavior.
Key Resources:
Create and distribute internal investigation guidelines/policy to all employees, Define the process to intake and triage employee reports of misconduct, Create a central repository for identified reports of misconduct, Designate a single point of contact to process (assign, escalate, monitor, and close-out) employee reports of misconduct, Select trained, qualified, and experienced personnel to conduct internal investigations.
Evaluate
Expectations are met through effective checks and balances and taking consistent and appropriate disciplinary measures to discourage unethical conduct while also rewarding those who demonstrate ethical behavior.
Key Resources:
Collaborate with Risk function to monitor mitigation steps, Identify metrics for an effective compliance program and report metrics to leadership, Track compliance program activity, Benchmark compliance program against similarly sized and situated industry peers
